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This limitation is "the aggregate of all amounts each of which is an amount that can reasonably be considered to be the amount that (the taxpayer) would have deducted under (paragraph 111(1)(b)) had (paragraph 127.52(1)(d)) been applicable in computing the amount deductible under that paragraph". ...

These payments are considered retroactive performance adjustments: however, the payments do not reflect a permanent adjustment to the base salary. ...

Where the terms and conditions of a contract indicate that an employer-employee relationship exists between the payer and the caregiver for the purpose of the Income Tax Act, the Unemployment Insurance Act and the Canada Pension Plan, the amount received by the employee for services rendered is considered employment income. ...

Our Opinion We have carefully reviewed and considered all the facts and information you provided to us with respect to the XXXXXXXXXX loan, including the arguments put forward by the taxpayer's advisor,XXXXXXXXXX in his submission to you dated August 17, 1993, and the copy of the XXXXXXXXXX Participation Agreement. ...

Under subsections 104(4) and 104(5) of the Act, non-resident trusts would be deemed to have disposed of their taxable Canadian properties, at the end of the day specified under subsections 104(4) or 104(5.3) of the Act, at fair market value and considered to have reacquired them, immediately thereafter, at a cost equal to the same fair market value. ...

It is reasonable that the cost of goods in inventory that are current assets should be kept separate from the cost of goods in inventory that are noncurrent assets, even where the goods are otherwise considered to be identical. ...

We understand that, to the best of your knowledge and that of the taxpayer, none of the issues involved in the ruling request is: (i) in an earlier return of the taxpayer or a related person, (ii) being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayer or a related person, (iii) under objection by the taxpayer or a related person, (iv) before the courts, or (v) the subject of a ruling previously issued by the Directorate to the taxpayer or a related person. ...

All the facts of a particular situation would need to be considered. Roberta Albert for Director Business and Publications Division Income Tax Rulings Directorate Policy and Legislation Branch?? ...

Thus GAAR would apply to the series of transactions comprised of the sale of shares by the Employee to Sidecar Co. and the acquisition of such shares by Company X unless it may reasonably be considered that the transactions would not result directly or indirectly in a misuse of any of the provisions of the Act or an abuse having regard to the provisions of the Act read as a whole (subsection 245(4) of the Act). ...

In the case of a person who is deemed to be resident of Canada pursuant to the 183 day rule it is quite likely that the "tiebreaker rule" will go in favour of the other country and such a person will be considered resident of the other country for the purposes of the treaty.  ...